Code of Business Conduct

CODE OF BUSINESS CONDUCT


Compliance with Laws, Rules and Regulations
Employees must respect and follow applicable government laws, rules and regulations at all times. Compliance with all applicable National, European and International laws and regulations must never be compromised. Additionally, employees shall adhere to internal company rules and regulations as they apply in any given situation. Those internal rules are specific to the Company and may go beyond what is required by the law.
Conflicts of Interest
Employees are expected to use their judgment to act, at all times and in all ways, in the best interests of Mediline Isothermal Solutions. Conflict of Interest may occur when personal interests of an employee compete with the interests of Mediline Isothermal Solutions or an employee's business or personal relationship with a customer, supplier, competitor, business partner, or other employee, impairs the employee's objective business judgment. In such a situation, the employee should promptly notify his/her Supervisor Manager and/or the Senior Management Team to resolve the situation in a fair and transparent way. Employees should avoid Conflicts of Interest whenever possible.
Outside Activities and Company’s Confidential Information
Company’s employees may perform activities outside the Company, provided that such outside work does not create risks for Mediline Isothermal Solutions’ reputation, is not to the detriment of their position and responsibilities at the Company and does not lead to a Conflict of Interest. Nevertheless, it is important for the employees to protect the Company’s nonpublic information, which includes everything, from contracts and pricing information to strategic marketing plans, technical specifications, new product design and development parameters, financial data, etc.
Health and Safety
Mediline Isothermal Solutions is committed to maintaining the highest professional and ethical standards for a healthy, safe and supportive working environment which helps our people and our company to flourish. Each employee has responsibility for maintaining a safe and healthy workplace by following safety and health rules and practices and reporting accidents, injuries and unsafe conditions, procedures and/or behaviours. Violence and threatening behaviour are not permitted. Employees must report to work in a condition to perform their duties, free from the influence of illegal drugs or alcohol.
Family and Friends
Immediate family members and partners of employees may be hired as employees or consultants only if the appointment is based on qualifications, performance, skills and experience. These principles of fair employment will apply to all aspects of the employment, including compensation, promotions and transfers, as well as in case that the relationship develops after the respective employee has joined Mediline Isothermal Solutions. In addition, personal relationships at work must not influence the employee’s ability to act in the best interest of the Company, and must not affect any other employment relationship. Furthermore, employees with relatives / friends who are employed by customers or suppliers of Mediline Isothermal Solutions should notify his/her Supervisor Manager and/or the Senior Management Team. The personal relationships do not create a conflict under the Code, unless: They influence the Mediline Isothermal Solutions employee’s ability to act in the best interest of the Company, and/or if they affect, or appear to affect, Mediline Isothermal Solutions customer’s or supplier’s own Code of Business Conduct Finally, employees with relatives / friends who are employed by competitors of the Company should notify his/her Supervisor Manager and/or the Senior Management Team. Employees are obligated to protect the Company’s nonpublic information at all times, including outside of the workplace and working hours, and even after employment ends. Execution of a confidentiality agreement may be necessary to prevent disclose of nonpublic information to anyone, including family and friends, outside the Company.
Privacy
Mediline Isothermal Solutions respects the privacy of all its employees, business partners, suppliers and customers. Any personal data must be handled with great responsibility and in compliance with all applicable privacy National, European and International laws. Employees who handle the personal data of others must: Act in accordance with applicable privacy National, European and International law. Act in accordance with any relevant contractual obligations. Collect, use and process such information only for legitimate business purposes. Limit access to the information to those who have a legitimate business purpose for seeing the information, and Take care to prevent unauthorized disclosure
Corporate Opportunities
Employees shall avoid investments which could interfere, or appear to interfere, with the ability to make decisions in the best interest of the Company, is to the detriment of their position and responsibilities at the Company and does not compete with the Company which would lead to a Conflict of Interest. Nor shall they take personal advantage of business opportunities that they discover during their employment, unless the Company expressly waives its interest in pursuing such opportunity. If employees want to pursue business opportunities that might be of interest to the Company, they shall inform the Senior Management Team who will seek a management decision as to whether or not the Company wants to pursue the opportunity. Even if the Company decides against pursuing the opportunity, the employee may seize the opportunity on his or her own behalf only if it is clear that doing so will not result in direct or indirect competition with the Company’s operations.
Antitrust and Fair Dealing
Mediline Isothermal Solutions is governed by the principles of honesty, fairness and mutual respect to customers, suppliers and competitors. The Company acts and will always do so in full compliance with all applicable antitrust, competition and fair dealing National, European and International laws. Therefore, the Company’s employees must not be engaged in any illegal or illicit activity to obtain competitive information and accept, disclose or use competitive information that is known or is believed to be disclosed in breach of a confidentiality agreement between a third party and one of the Company’s competitors. Commercial policy and prices will be set independently and will never be agreed, formally or informally, with competitors or other non-related parties, whether directly or indirectly. All employees, but especially those who are involved in marketing, sales and purchasing, or who are in regular contact with competitors, have a responsibility to ensure that they are familiar with applicable competition laws.
Accountability and Transparency
Mediline Isothermal Solutions employees are provided with various resources and facilities to accomplish their duties. All employees shall ensure that the Company’s resources are not wasted or used improperly or extravagantly and shall seek to protect the Company’s property from loss, damage, theft, fraud, embezzlement and destruction. The Company assets must not be used for personal benefit or the benefit of anyone other than Mediline Isothermal Solutions. These obligations cover both tangible and intangible assets, including know-how, confidential or proprietary information and information systems. Employees must never engage in fraudulent or any other dishonest conduct involving the property or assets or the financial reporting and accounting of Mediline Isothermal Solutions or any third party. This may not only entail disciplinary sanctions but also result in criminal charges. To the extent permitted under applicable law, the Company reserves the right to monitor and inspect how its assets are used by employees, including inspection of all e-mail, data and files kept on Company network terminals.
Bribery – Corruption, Gifts and Meals
Mediline Isothermal Solutions employees must never, directly or through intermediaries, bribe anyone for any reason, whether in dealings with the public or the private sector. Nor must they accept any bribe in return for any preferential treatment of a third party. Moreover, employees must refrain from any activity or behaviour that could give rise to the appearance or suspicion of such conduct or the attempt thereof. Employees should be aware that the offering or giving of improper benefits in order to influence the decision of the recipient, even if he or she is not a government official, may not only entail disciplinary sanctions but also result in criminal charges. Employees who are conducting business with the government officials of any country must contact the Legal Department of Mediline Isothermal Solutions for guidance on the law governing payments and gifts to governmental officials. Employees must not accept gifts, meals or any other favor, from customers or suppliers if doing so might compromise, or appear to compromise, the ability to make objective business decisions in the best interest of Mediline Isothermal Solutions employees must not be influenced by receiving favours nor shall they try to improperly influence others by providing favours. Employees may only offer or accept reasonable meals and symbolic gifts which are appropriate under the circumstances and do not create the impression of improperly influencing the respective business relationship. No employee shall offer to or accept from any third party gifts taking the form of any of the following, whatever the value involved: Money Loans Kickbacks Similar monetary advantages
Discrimination and Harassment
Mediline Isothermal Solutions provides equal opportunity in all aspects of employment and does not tolerate any illegal discrimination or harassment of any kind. The Company respects the personal dignity, privacy and personal rights of every employee and is committed to maintaining a workplace free from discrimination and harassment. Therefore, employees must not discriminate on the basis of origin, nationality, religion, race, gender, age or sexual orientation, or engage in any kind of verbal or physical harassment based on any of the above or any other reason. Any employee, who believes that he or she has been subjected to harassment, bullying or unfair discrimination, or any other form of workplace intimidation or dispute, should raise their concerns with the supervisor Manager, HR Department and/or the Senior Management Team.
Failure to Comply – Reporting Illegal or non–compliant Conduct
All employees must read the Code of Business Conduct and Ethics and agree to abide by its provisions. It is each employee’s responsibility to ensure full compliance with all provisions of this Code and to seek guidance wherever and whenever necessary. Failure to read the Code does not excuse an employee from compliance with the Code. Employees shall report any practices or actions believed to be inappropriate under this Code or even illegal to the respective members of the HR Department or the Senior Management Team. All complaints shall be properly investigated. Mediline Isothermal Solutions prohibits retaliation against any employee for such reports made in good faith, while it also protects the rights of the incriminated person. Any failure to comply with this Code may result in disciplinary action, including the possibility of dismissal and, if warranted, legal proceedings or criminal sanctions.